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SALA v. COMMISSIONER OF INTERNAL REVENUE

No. 7.

146 F.2d 228 (1944)

SALA v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

December 18, 1944.

Attorney(s) appearing for the Case

Richard J. Cronan and M. Robert Gallop, both of New York City (George Trosk, of New York City, of counsel), for petitioner.

Morton K. Rothschild, of Washington, D. C., Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, Sp. Asst. to Atty. Gen., for respondent.

Before L. HAND, AUGUSTUS N. HAND, and CHASE, Circuit Judges.

L. HAND, Circuit Judge.

This appeal is from an order of the Tax Court, assessing against the petitioner a deficiency in income tax for the year 1935. For a number of years she had been the sole shareholder in two companies, each owning a large building in the City of New York: One called the Broadex Realty Corporation, and the other Ideal Investing, Inc. Until 1928, her husband was president of both these companies, and managed their business; and she had no part...

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